FACTS
Antero Sison, in his capacity as a taxpayer, alleged that Sec. 1 of BP 135 -- which imposed higher tax rates on taxable net income than on taxable compensation income -- is arbitrary, oppressive and capricious in character as it unduly discriminates between those earning a fixed income and those who are not.
His main argument was that the said provision violates the due process and equal protection clause of the Constitution, as well as the rule requiring uniformity in taxation.
RULING
The Court ruled in favor of the State, saying that BP 135 is not unconstitutional.
The SC ruled that the subject provision does not transgress the controlling doctrines of due process, equal protection, and uniformity in taxation.
It does not violate the due process clause it was neither of the following: (1) beyond the jurisdiction of the state, (2) not for public purpose, or (3) in case of a retroactive statute, must be harsh and unreasonable.
It does not violate the equal protection clause because individual taxpayers earning a fixed income are situated differently from those not earning a fixed pay, which means the tax statute is justified in treating them differently.
Lastly, the subject provision is valid because its classification or differentiation is based on the practical dictates of justice and equity, not discriminatory, and is therefore uniform.
